In the list of new non-hazardous waste materials solid waste that was recently released by the US Environmental Protection Agency (EPA), used tires were included in this list. In response, the American Tire Industry Association and the American Rubber Manufacturers Association publicly expressed their opposition on August 3 and August 5, respectively, saying that the US Environmental Protection Agency's inclusion of used tires for the production of recycled fuel in the “blacklist†is bound to increase the use of used tires. Stocks increase public health and safety risks.
According to the EPA's solid waste list, used tires can only be used for renewable fuel production if most of the steel wire is removed, otherwise they will be treated as solid waste. According to the new regulations, if waste-recycled tire fuels with higher energy efficiency than conventional fuels are used, companies must adopt a large number of emission control measures. Previously, EPA has defined waste tires as a legitimate source of industrial supplemental fuel. The EPA's own data also shows that when waste tires' regenerative fuels are burned, whether or not they are removed, they have higher energy efficiency than coal combustion (12,000 to 16,000 BTUs/lb), and emissions are equivalent to or lower than coal.
The American Rubber Manufacturers Association stated in a public statement that EPA does not have the right to classify waste tires used for recycled fuel as solid waste. In addition, when waste tires are used for regenerative fuels, steel wires not only have no impact on the total emissions, but they can also be used as auxiliary raw materials for cement production.
According to the American Tire Industry Association, after the implementation of the new proposal, if the used tires are recycled fuel, their combustion equipment must meet the more stringent emission regulations in Article 129 of the U.S. Clean Air Act. These companies will be forced to abandon the use of renewable fuels, while replacing or renovating combustion equipment. The American Rubber Manufacturers Association also believes that a large increase in waste tire regenerative fuel emission control measures, will inevitably lead to high extra expenses, prompting some users to switch to the use of coal and other low-efficiency, higher emissions of traditional fossil fuels. As a consequence, the use of high-emission fuels has increased and air pollutants have increased; the amount of recycled fuel for tires has been drastically reduced, and at least millions of used tires have been directly deposited in landfills, storage sites, and even illegal dumping sites because they have not been utilized.
Tracey Norberg, senior vice president of the American Rubber Manufacturers Association, said: "The EPA's proposed management system will destroy the US tire reclaimed fuel market and will affect the entire waste tire industry. Worse, it is safe. And the management system that effectively reduces the accumulation of used tires will collapse. EPA's counter-proposal proposal will cause harm to the environment, and it will also lead to the unemployed of thousands of workers working in the waste tire industry."
Dick Gust, former president of the American Tire Industry Association, said that such harsh treatment of used tire reclaimed fuels will undermine the balance of the tire's value chain and the tiresome terrain of tires is likely to reappear. Although the U.S. industry is working hard to find more high-end applications for waste tire-derived materials, it is undeniable that the main way out of U.S. scrap tire use is still in renewable fuels.
The American Waste Tire Management System is a successful example of the globally recognized and environmentally friendly management system in the rubber industry. According to data from the American Rubber Manufacturers Association, there were more than one billion tires piled up in the United States in 1990, and only 11% of the new tires that were produced that year were reused. At present, the number of used tires piled up in the United States has fallen below 100 million, and nearly 90% of the newly generated used tires are reused each year. Fifty-two percent of the 300 million scrap tires produced in the United States in one year are used as renewable fuels for cement, paper, industrial boilers, and other public utilities.
The American Rubber Manufacturers Association believes that the EPA should reconsider this proposal with serious flaws, and recommends that newly-produced used tires be allowed to be used for regenerative fuels, and that only historically accumulated used tires should be included in the solid waste category.
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